The Danish Parliament enacted Bill No. L 13 on December 7, establishing a deadline for the preparation of Danish transfer pricing documentation. Danish taxpayers are required to prepare transfer pricing documentation in line with the Organisation for Economic Co-operation and Development's concept of a local file, a master file, and Country-by-Country (CbC) report under Action 13 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The documentation must be submitted to the tax authorities within 60 days of a request. However, the law does not specify any deadline for the preparation of the documentation. In pending cases, the tax authorities are taking the position that the documentation must be prepared by the deadline for the corporate income tax return, which generally is six months after the end of the financial year, e.g., June 30 for companies with calendar year accounts. It has now been codified that transfer pricing documentation must be prepared by the deadline for the tax return.

A Global Tax Alert, attached below, provides additional details.

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ATTACHMENT

Full text of Tax Alert 2017-2076